Having studied numerous planning applications over
the years this one has been exceptionally badly handled by Capital and
Regional. Their first attempt at public consultation last year boiled down to
“what type of bush would you like” – they refused to discuss anything but the
landscaping. There was blatant misleading information as we were told the
avenue of lime trees “would not be touched as they are listed”.

The attempt this year was even worse as it was just
a montage of the various development sites in the town centre with no detail of
the proposed scheme. Seeing as officers would have been in discussions with
them for at least a couple of years that was insulting to residents.

The officers formally logged the planning
application in April but it was only made public in late June with a 21 day for
objections. In that time there could have been meaningful consultation with the
public explaining in great detail what is proposed and its implications for
town centre users. After we complained to the Chief Executive the plans were
moved to the consultation site but it should not have needed our complaint to
achieve access to the plans.

Capital and Regional have made no effort to engage
with the public and for that reason alone their scheme should be refused.

We wish to object to the above application on the
grounds of poor design and damage to the street scene and loss of open space.

1.Town Square

With the increase in numbers of people expected to
use the Town Square, 500 extra dwellings in this development let alone the
others in central Walthamstow amounting to at least 2,000 dwellings, it makes
no sense to reduce the open space. It is contrary to the London Plan which
states:

7.16 The quality of the public realm has a
significant influence on quality of life because it affects people’s sense of
place, security and belonging, as well as having an influence on a range of
health and social factors. For this reason, public and private open
spaces, and the buildings that frame those spaces, should contribute to the
highest standards of comfort, security and ease of movement possible. This
is particularly important in high density development (Policy 3.4). Open
spaces include both green and civic spaces, both of which contribute to the
provision of a high quality public realm (see Policy 7.18). The character
of the public realm that leads into major green spaces, especially for
pedestrians is key to the integration of green infrastructure and landscape
into the urban fabric. Legibility and signposting can also make an important
contribution to whether people feel comfortable in a place, and are able to
understand it and navigate their way around. Ongoing maintenance of this
infrastructure should be a key consideration in the design of places and
secured through the planning system where appropriate. Managed public
spaces in new development should offer the highest level of public access.

The proposed plan fails to meet this objective.
People no longer feel safe with tower blocks looming around them, the amount of
open space is being dramatically reduced and what is left is being built on
i.e. playground, fountains etc. With ever more people being encouraged in to the
centre the open space has to be increased not reduced.

Tall buildings close to Selbourne Road will result
in a loss of the view of the Town Square and reduce the impact and benefit of
the of opening up and greening of the area contrary to the London Plan policy.

The Wood Street water feature only lasted a couple
of years before it was completely removed making a significant saving for the council.
This is what will happen with any water feature in the Town Centre – the
council will not be able to maintain it and it will soon look an eyesore.

2.Trees

The loss of trees in the avenue of Limes is pure
vandalism. Residents enjoy these mature trees and always state they want them
to remain. These plans destroy large areas of the avenue which will not be
replaced by re-planting. It takes decades for trees to look and have the
environmental benefit these trees provide and must not be destroyed. Again it
is contrary to the London Plan.

7.17 The public realm should be seen as a
series of connected spaces that help to define the character of a
place. Places should be distinctive, attractive, and vital and of the
highest quality, allowing people to meet, congregate and socialise, as well as
providing opportunity for quiet enjoyment. They should also, wherever
possible, make the most of opportunities to green the urban realm through new
planting or making the most of existing vegetation. This will support the
Mayor’s aims for two million trees to be planted in London by 2025 and, to
secure additional greening in the Central Activities Zone (CAZ) to help
mitigate the urban heat island effect (Policy 5.10). Encouraging
activities along the waterways can also contribute to an attractive townscape
and public realm

3.Town Centre Design
Objectives

LBWF Town
Square Design Objectives state “minimise
loss of open space and demonstrate that improvements provided by the
re-imagined Town Square compensate for any proposals to reduce openspace.” Clearly by reducing the open
space and destruction of the trees this objective is not met.

4.Density and Massing

The 4
proposed tower blocks, being huddled together in one corner of the whole Mall
shopping site, clearly create an unacceptable cluttered view because of the massing
of the blocks. Despite the PTAL argument most people will see that these blocks
are close together and very dense and not attractive. The plans as presented
show 4 blocks squeezed into one corner rather than laid out across the whole
site. If 4 blocks are needed the Mall should be demolished and the whole site
properly designed to layout the tower blocks in an attractive way with decent
spaces between them.

5.Fire Risk

In the
case of a fire taking hold in one of the tower blocks there is not enough room
for the emergency services to reach people trapped in the blocks.

6.Design

One of the
reasons why Walthamstow is proving so attractive is its miles of Victorian and
Edwardian houses. These are normally two storeys. The market by definition is
at ground level along the High Street and is a major attraction for visitors
and residents. New building should be restricted to 5 or 6 storeys to blend in
with the surrounding area. Clearly 4 tower blocks including one at 29 a storey
fails completely to blend in to its surroundings.

Again this
plan fails to meet the objectives of the London Plan Section 7.7

C Tall and
large buildings should:

a generally be
limited to sites in the Central Activity Zone, opportunity areas, areas of
intensification or town centres that have good access to public transport

b only be considered in areas whose character would not
be affected adversely by the scale, mass or bulk of a tall or large building

c relate well to the form, proportion, composition,
scale and character of surrounding buildings, urban grain and public realm
(including landscape features), particularly at street level;

d individually or as
a group, improves the legibility of an area, by emphasising a point of civic or
visual significance where appropriate, and enhances the skyline and image of
London

e incorporate the highest standards of architecture and
materials, including sustainable design and construction practices

f has ground floor activities that provide a positive relationship
to the surrounding streets

g contribute to improving
the permeability of the site and wider area, where possible

a should not affect their surroundings adversely in
terms of microclimate, wind turbulence, overshadowing, noise, reflected glare,
aviation, navigation and telecommunication interference

b should not impact on local or strategic views adversely

7.Design and Access Statement

The Design
and Access Statement says the purpose of the tower blocks is to “by reputation
and by physical presence, promote Walthamstow in a wider London context and
mark the location of the Town Square”. The redesign of the adjoining public
space “which presently performs poorly and adds little to the enjoyment of
visiting the Town Centre”.

This is
wrong and irrelevant. Everyone who needs to know where the Town Centre is knows
it and does not need an eyesore tower block to show the way. Ilford has an even
higher block and the result is miserable and tatty surroundings to a mediocre
town centre. The current town square with open space is enjoyed by numerous
visitors, in particular parents with children who can let them play on the
grass mounds. The proposed replacement will not add any enjoyment to the
cramped and overcrowded new open space.

8.Underground Line

It goes
without saying the tube line that runs under the site must be protected from
any disturbance – remember when the Link Road was built under the Green Man
roundabout the Central Line tube tunnel was accidentally bored into. This is a
very tight space for 4 tower blocks and there is a real danger to the tube
tunnels. It is not worth the risk allowing these towers to be built especially
as people will be reluctant to move in after the Grenfell fire.

9.Shopping Mall

Capital and
Regional want to keep the shopping centre open to ensure they don’t lose
revenue, but at what risk to shoppers? How can 4 tower block foundations be piled
without disturbing shoppers and staff in the shopping centre? If it is disrupted too much people will find
other places to shop; easy via the Victoria Line and bus network, so the
existing jobs will be under threat – again this is not a price worth paying for
a badly designed scheme.

10.Construction Traffic

What
restrictions will the council be putting on the construction traffic to ensure
the Town Centre roads are not ground to a halt? The existing traffic is often
clogged and if the South Grove site starts work at the same time as this there
will not be enough road capacity. Nowhere in the plans available to the public
is there any information about how they propose to bring heavy lorries to the
site and how many they will need on a daily basis for some years.

We urge you
to reject this ill-conceived scheme which will ruin a popular shopping centre,
destroy current open space and mature trees and cause years of disruption while
it is being built. There are already enough building sites in Walthamstow!